Mercury Reduction Plan (MRP)

1. Mercury Reduction Plan (MRP) Big Rapids Ordinance NO. 521-08-03 Chapter 53, Title 5, Section 53.021(B) Mercury Reduction Plans

3. Potential Mercury Source(s) Potential source of Mercury Location within Facility Potential source of Mercury Location within Facility Potential source of Mercury Location within Facility Potential source of Mercury Location within Facility Potential source of Mercury Location within Facility

4. Quantifiable BMP Strategies 1.Replace known mercury source with non-mercury 2. Segregate mercury source from sanitary sewer discharge. 3. Determine and implement alternative disposal methods for mercury source. 4. Recycle mercury source chemical to prevent sanitary sewer discharge. 5. Purchase mercury spill kits and implement plan to contain spilled Hg product. 6. Improve housekeeping practice to prevent Hg from reaching sanitary sewer. 7. Implement alternative production processes which do not require the use of Hg containing reagent. 8. Document the number of dental procedures where Hg was replaced or installed with a nonmecury material. 9. Other Mercury reduction strategies.

5. TRADITIONAL STRATAGIES 10. Create a baseline monitoring program to test for Hg over a given period of time to show reduction of discharge. 11. Sample individual sinks and internal locations to locate/ trace previously unidentified Hg sources for reduction. 12. Power flush and vactor sewer lines to remove residual Hg contained in lines. 13. Remove Hg from lines using sodium sulfide and vactoring to collect Hg. 14 Reline and / or replace lines containing Hg. 15. Implement a program for sink trap cleaning. Segregate sink trap residuals for proper disposal. 16. Install and maintain additional sink traps. 17. Evaluate and install pretreatment where appropriate. 18. Replace Hg containing equipment susch as pump switches, thermostats, and as identified. 19. Implement other mercury treatment style strategies.

7. Demonstration of Mercury Source Reduction /Elimination The reduction/elimination of mercury discharges to the sanitary sewer is demonstrated and or documented by: ________ Our analytical results show a reduction in mercury discharges at the outfall. (Please include laboratory results from the latest quarter); ________ Our internal monitoring / sampling for mercury shows a reduction. ( Provide laboratory results from individual lines, sinks, and traps); ________ Other method(s) of demonstrating reduction. Describe. ________ The effectiveness of our reduction efforts has been has/not been demonstrated. (Describe for each source and strategy.)

8. Mercury Reduction Plan (MRP) Semiannual Report The semiannualreport is due on or before Janruary 10 and July 10 of each year until the MRP is completed and the POW has notified your facility to discontinue these reports. The MRP semiannual report may be submitted and updated on this form Please keep an original copy of this for your records. The MRP Semiannual Report consists of the cover sheet, a certification of progress, and the following attachments reflecting the activities of the last two quarters. Failure to update the attachments will constitute noncompliance with the MRP requirements. The following Updated attachments are required: 1. Quarterly analytical results for mercury monitoring at the outfall. 2. Updated MRP source sheets. 3 Updated MRP action sheets ( if used)

9. MRP CERTIFICATION; As an authorized representative for ________________________________________, I hereby certify that to the best of my knowledge my company has implemented a Mercury Reduction Plan in accordance with the requirements of our plan. I have reviewed the attached Mercury Reduction Plan Semiannual Report and updated attachment and find these to be an accurate description of our mercury reduction progress to date. Our goal is to reduce mercury discharges into the sanitary sewer system < 0.2 mg/l within three years of our Mercury Reduction Plan approval date. I certify under penalty of law that this document and al attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the persons who manage the system , or those persons directly responsible for gathering the information, submitted is to the best of my knowledge and belief,true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations. SIGNED __________________________________________ DATE _________________________ PRINT NAME ___________________________________________

10. Time Line for Strategy action Date implemented Date of Completion Mercury Source Removal Strategy _____________ _____________________________________ __________ ________________ _____________ _____________________________________ __________ ________________ _____________ _____________________________________ __________ ________________ _____________ _____________________________________ __________ ________________ _____________ _____________________________________ __________ ________________ _____________ _____________________________________ __________ ________________ _____________ _____________________________________ __________ ________________ _____________ _____________________________________ __________ ________________ _____________ _____________________________________ __________ ________________ _____________ _____________________________________ __________ ________________ _____________ _____________________________________ __________ ________________ _____________ _____________________________________ __________ ________________ _____________ _____________________________________ __________ ________________